Online Buyer’s Club Privacy Policy

Last Updated: September 27, 2019

Thank you for using Online Buyer’s Club, the premier technology platform connecting independent, licensed cannabis retailers with verified users. This Privacy Policy applies to your use of Online Buyer’s Club, Online Buyer’s Club platform, and any websites, mobile applications, services, programs, or features (the “Online Buyer’s Club”) owned or operated by Online Buyer’s Club Tecnologies Inc. and any of its subsidiaries or affiliates (collectively, “Online Buyer’s Club,” “we,” “our,” or “us”). Online Buyer’s Club values your privacy, and taking proper care of your information is a top priority for us. Our goal is to help you understand what information we collect (also known as “User Data”) and describe how we use that information to provide you and all of our users with safe and secure access to legal cannabis, industrial hemp-derived CBD, and other products and accessories.

This Privacy Policy is part of, and is governed by, the terms and conditions set forth in our Terms of Service, including any agreements incorporated by reference within the Terms of Service (the “Online Buyer’s Club Terms”). Any terms not defined in this Privacy Policy shall have the meaning given to them in our Terms of Service. If you do not feel comfortable with any part of this Privacy Policy or our Terms of Service, you should stop using or accessing the Online Buyer’s Club Platform and terminate your Account.

 

INFORMATION WE COLLECT

Information You Provide To Us

Registration and Identity Verification

When you sign up for any Online Buyer’s Club account, you give us your name, email address, phone number, date of birth, and, if necessary, a copy of your government-issued ID (i.e. your driver’s license, state ID card, or passport). In order to receive a delivery or shipment, you must provide a valid delivery address — whether that’s your home address or any other valid physical address. Such information is a part of what’s called your personally identifiable information (“PII”) as this is data that can be used to specifically identify you. Additional PII we receive may include, but is not limited to, a state-issued medical Delta 8 THC ID card or a physician’s recommendation letter that you provide us in order to receive a medical delivery. This PII helps us establish and maintain your user account, verify your identity, remain compliant with state and local laws, and ensure that you are of legal age to receive a delivery or shipment.

Demographic Information

We also collect demographic information from you when you register, when you take our surveys, and throughout your use of the Online Buyer’s Club Platform. This information on its own cannot be used to specifically identify you, but we may use it to learn more about our users and their habits and preferences. Demographic information may include your age, gender, location, how you heard about Online Buyer’s Club, spending habits, and other preferences or habits.

Communications

If you contact us directly, we may collect information from you that helps us provide a satisfying experience and answers any questions you have while using Online Buyer’s Club. For example, when you communicate with a member of our customer service team, we may ask you for your name, email address, delivery address, phone number, or proof of charge in order to identify your account, confirm your identity, or assist with your issue. If you send us an email, we will collect the contents of that email and any other information you choose to provide. If you communicate with us via live chat, that correspondence will be archived. If you communicate with us via social media, we collect that communication and associate that information with your user account. Customer service communications over the phone may be recorded for quality control purposes and may be summarized within our customer support systems.

Payment Information

Payment information may be collected in connection with a transaction facilitated by Online Buyer’s Club.

For on-demand delivery, all payments are made to a third-party, licensed cannabis retail dispensary fulfilling your order, and not to Online Buyer’s Club. For other products and services, payments may be made directly to Online Buyer’s Club or another third party. In all cases, while we may retain a limited amount of payment information for identification and convenience, to keep your financial data secure, we do not store full payment or financial information on our servers. Unless otherwise noted, payment information flows through a third-party vendor who processes the payments for Retailers and Online Buyer’s Club.

Voluntary User Surveys

From time to time, we may invite you to fill out voluntary user surveys to provide feedback on various topics which may include: your experiences with Online Buyer’s Club and/or our partners, available products, new services, your preferences related to cannabis, and your sentiments on public policy or other cannabis industry topics. These surveys are often conducted by third-party market research firms, who collect such data to analyze industry preferences and trends. Online Buyer’s Club does not share your survey information on an individualized basis, and does not share this data for direct marketing to our users.

Information We Collect When You Use Online Buyer’s Club

Location Information

We collect your location information and we may use geolocation-based services in order to verify your location. For instance, knowing your location may be necessary to allow you full access to our mobile apps or certain aspects of the Online Buyer’s Club Platform. Furthermore, for compliance reasons, some of the Online Buyer’s Club Platform may be restricted depending on where you are located. Location information helps us connect you with a licensed retailer that services your delivery area, send you relevant content based on your location, and optimize or improve our products and services. Location data may also be collected as demographic information.

Usage Information

To help us understand how you use Online Buyer’s Club and to help us improve our services and products, we automatically collect information about your interactions with the Online Buyer’s Club Platform. This includes, but is not limited to, the products and content you view, your actions on the Online Buyer’s Club Platform, how you access our Online Buyer’s Club Platform, and the details of any orders you place.

Device Information

Online Buyer’s Club collects information about the devices you use to access the Online Buyer’s Club Platform. Our servers receive and store information about your IP address, web browser, mobile operating system, phone carrier and manufacturer, unique identifiers such as advertising ID, VIN, MAC address, and IDFA, and other related software or hardware information related to your devices.

Cookies and Technical Information

We also collect information through the use of “cookies,” tracking pixels, and similar technologies. Cookies are small text files created by websites and stored on your device. They provide a way for the Online Buyer’s Club Platform to recognize you and keep track of your settings and preferences. We use cookies and similar technologies to provide you with a secure experience and to understand, among other things, how you navigate the Online Buyer’s Club Platforms, learn what content is popular, recognize repeat users, and save your account information. While most browsers allow you to deny the use of cookies, at this time the Online Buyer’s Club Platform is not configured to read or respond to “do not track” settings or signals in your browser headings.

Call and Text Information

We work with third-party partners to facilitate phone calls and text messages, including communications between you and your driver. We collect information about such communications, including the date and time of the call or SMS message, the parties’ phone numbers, and the content of any SMS messages.

User Feedback

We want to make sure you have a consistently positive experience with the Online Buyer’s Club Platform, and we are always looking to improve our products and services. Accordingly, we collect and retain information about any ratings, reviews, and feedback you provide about our service, the Online Buyer’s Club Platform, the products on our site, our licensed retail partners, and their drivers.

Information Collected from Third Parties

Retailers

When you place an on-demand delivery order through Online Buyer’s Club, that order is fulfilled and delivered to you by one of our licensed retail partners. We collect information about you from the retailers or their drivers based on your interactions with them. For instance, when your delivery driver reaches the delivery address you provided, he or she will check your government-issued ID and ask for your signature before completing the transaction. In certain jurisdictions, when required by local law or regulation, your delivery driver will also scan the barcode on the back of your government-issued ID to confirm that the information displayed on the ID is accurate. You may also communicate with your driver via text or phone call in order to complete the delivery. While we collect this information about you through the retailer, please note that this Privacy Policy does not cover the information or privacy practices of retailers.

Third-Party Partners

We may collect information about you directly from our third-party partners, services, or tools if your use of their services led to or related to your use of Online Buyer’s Club. We may also utilize such third-party services as a means of collecting information from you as described above. The information we collect from partners will be treated in the same manner as the information we collect from you.

HOW WE USE THE INFORMATION WE COLLECT

We use the information we collect from you to:

  • Provide the Online Buyer’s Club Platform to you, including, but not limited to, connecting you with a licensed retailer and drivers to facilitate your legal access to cannabis and cannabis products, shipment of professionally curated, hemp-derived CBD products, facilitation of your transactions and payments
  • Support our licensed retail partners with information necessary for them to maintain their records in accordance with their normal business practices and applicable law
  • Identify you as a user in our system
  • Comply with applicable laws
  • Analyze and assess current and potential user markets
  • Improve, optimize and create new products and services
  • Evaluate retailer, brand, and other third-party partnerships
  • Personalize your experience with Online Buyer’s Club
  • Provide customer support and assist with your access or use of the Online Buyer’s Club Platform
  • Communicate with you, either directly or through one of our partners, including for marketing and promotional purposes
  • Facilitate your communication with the driver fulfilling your order
  • To engage in marketing activities with you and to assess marketing and promotional initiatives
  • Detect, prevent, or mitigate fraud or any other suspicious activities
  • Conduct research and development, such as by conducting voluntary user surveys or obtaining other feedback from you
  • Create aggregated, de-identified and/or anonymized data, such as for educational content
  • Support ongoing efforts in cannabis legalization and social equity and justice
  • As otherwise described in this Privacy Policy or in any other notices we have or will provide to you.

HOW WE SHARE INFORMATION

We may share your information as described below:

To Facilitate Shipping

In order to facilitate deliveries, we share information with our business partners, including licensed retailers and their drivers. When you send an order to the retailer through Online Buyer’s Club, the retailer receives information required to complete your order, such as your first name, delivery address, order details, birthdate, and a picture of your face taken from your government-issued ID. The retailer connects you with a driver who fulfills your order, and the driver receives this information to complete the delivery. The driver never sees a full upload of your ID. When the driver arrives with your order, they will check your ID in person to verify your identity as required by law.

To Facilitate Shipping

Online Buyer’s Club uses a third-party logistics provider (“3PL”) in order to facilitate shipping of hemp-derived CBD products. When you order from the Online Buyer’s Club menu, the 3PL receives your name, shipping address, and order details so that they can send your items to the right place.

Affiliated Businesses

We may share your personal information with businesses that are legally part of the same group of companies that Online Buyer’s Club is part of, or that become part of that group (“Affiliates”). Affiliates may use this information to help provide, understand, and improve the Online Buyer’s Club Platform and Affiliates’ own services (including by providing you with better and more relevant experiences).

Anonymized, De-Identified and/or Aggregated Data

We share aggregated, de-identified and/or anonymized information for educational or informational purposes. Aggregated and anonymized means that user information is combined together with all PII removed so that any individual user cannot be identified. De-identified information means we have removed any identifiers that make a user identifiable, such as their name or address. We may also share anonymized, aggregated and/or de-identified data with third parties for consulting or independent research purposes. This data provides valuable information including how users interact with Online Buyer’s Club, our partners, available products, and also helps us drive conversation on consumer habits, preferences, and behavior within the cannabis industry.

Promotions and Referrals

If you signed up for a promotion with another user’s referral or promotion code, we may let your referrer know that their code was redeemed. However, we do not specifically identify the user that redeemed the code.

Third-Party Tools and Services

We may share your information with third-party service providers, business partners, consultants, tools, and services to facilitate Online Buyer’s Club operations such as compliance, marketing, communications, statistical analysis, hosting, database management, and a number of other functions. We share your information with these parties to the extent minimally necessary to perform their respective specific tasks on our behalf. We do not sell your information with third parties for direct marketing purposes by those parties, except as directed by you.

Government Authority, Law Enforcement, & Safety

Online Buyer’s Club does not proactively divulge your information to any local, state, or federal authorities. All of your information is securely stored and accessible only by authorized personnel. However, we will disclose information about you to a government authority, law enforcement official, or one of our partners if we believe we are required to by law, or in order to respond to or comply with regulations or legal processes, including, but not limited to, responding to subpoenas or warrants. We may also share your information if we think doing so is necessary to protect the rights, property, or safety of Online Buyer’s Club, our partners and their employees, our users, the public, or any particular person.

At Your Direction

There may be instances where you direct us to share personal information on your behalf, such as for medical records, for legal or administrative proceedings, or otherwise.

Acquisition or Merger of Online Buyer’s Club

In the event that all or a portion of the assets, business, or stock of Online Buyer’s Club are acquired by or merged with another party, your information may be among those assets transferred. An acquirer of Online Buyer’s Club or its assets may continue to use your information as described in this Privacy Policy. We will notify you with any choices you may have regarding your information as a result of such acquisition or merger.

Onward Transfer

If we share your PII as described in this Privacy Policy, we will seek assurances from the recipients of your PII, prior to transfer, that they will safeguard your PII in a manner consistent with this policy. Such assurances, where appropriate, may include contractual relationships with confidentiality clauses and non-disclosure agreements that provide the same level of commitment to safeguarding your PII as provided in this Privacy Policy.

YOUR CHOICES

We provide you with the choices below regarding your personal information:

Email Subscriptions

You can always unsubscribe from Online Buyer’s Club promotional emails by clicking the link provided at the bottom of the email. We will still send you transactional emails and receipts generated from your use of Online Buyer’s Club as these are not promotional communications.

Text Messages

You can opt out of receiving promotional text messages by texting the word STOP from the mobile device receiving the messages to the phone number you received the message from. Promotional texts are SMS messages sent to you containing offers, promo codes, or deal reminders. Standard messaging rates from your cell phone carrier will apply.

Push Notifications

You can opt out of receiving promotional push notifications through your device settings. Please note that opting out of receiving transactional push notifications, such as receiving a notification that your order has arrived, may impact your use of Online Buyer’s Club.

Location Information

You can prevent your device from sharing geolocation information at any time through your device settings. Please note that the use of geolocation information may be necessary to access some of our services, such as mobile apps that may only allow access to users in states that have legalized the sale of recreational cannabis.

Editing Account Information

You can review and edit your account information at any time by logging into your account and navigating to your “Account Settings.”

Deleting Your Account

We will store your PII as long as your account is open. If you wish to terminate, delete, suspend, or otherwise disable your Account or use of the Online Buyer’s Club Platform, please contact Customer Support. When we delete user accounts we must maintain certain information, including PII, as long as necessary to comply with legal obligations, prevent fraudulent activity, or to enforce agreements. Upon your request for deletion, the PII not necessary for such tasks will be deleted from your Account in reasonable amount of time.

REMINDERS

Changes to the Policy

We may update this Privacy Policy periodically. If we make any material changes, we will update you on the Online Buyer’s Club Platform, by email, or by other communication. We encourage you to stay up to date about our privacy practices by reviewing this Privacy Policy periodically. Continued use of Online Buyer’s Club following notices of changes to the Privacy Policy indicates your acknowledgment of such changes and agreement to be bound by the terms and conditions of such changes.

In addition, we may provide you with “just-in-time” disclosures or additional information about the data collection, use and sharing practices of specific parts of the Online Buyer’s Club Platform. These notices may provide more information about our privacy practices, or provide you with additional choices about how we process your personal information.

Age Restrictions

Online Buyer’s Club is intended for access and use by individuals who are of legal age for the services offered based on the applicable regulations of their state or other government entities (“Qualifying Age”). We do not knowingly collect PII or other information from or about anyone who is not of Qualifying Age. If you are not of Qualifying Age, you should not attempt to access or use Online Buyer’s Club, or send any information to us. If we discover that we have collected PII or other information from an individual who is not of Qualifying Age, we will take steps to remove that information.

Security

All of the information we collect is protected within our database, and we are committed to securing your information. Although we take reasonable, industry-standard precautions to protect your information, no security measures are 100% secure, and we cannot guarantee the full security of your information.

You are also responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails or physical mail between you and Online Buyer’s Club at all times. When you direct Online Buyer’s Club to share your information with third parties, please note that your privacy and security may also be affected by changes in such third party services. We are not responsible for the functionality, privacy, or security measures of any other organization or third party.